Motion Picture and Television 

Flight Operations Manual

2016

FLIGHT OPERATIONS MANUAL

ON THE WAVE PRODUCTIONS

ON THE WAVE PRODUCTIONS | 37 Humphrey Road Santa Barbara, CA 93108
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Table of Contents

Introduction ............................................................................................................................................ 2

Purpose............................................................................................................................................... 3

Organization Overview........................................................................................................................ 3

Company Snapshot.......................................................................................................................... 3

Contact Information ........................................................................................................................ 3

Designated Parties............................................................................................................................... 3

Participating Personnel........................................................................................................................ 4

Area of Operations.............................................................................................................................. 5

Plan of Activities.................................................................................................................................. 5

Permissions......................................................................................................................................... 5

Cordon Procedure ............................................................................................................................... 6

Pre-Flight Meeting............................................................................................................................... 6

FAA Sign-Off........................................................................................................................................ 7

Conditions to be Followed ................................................................................................................... 7

Communications................................................................................................................................ 13

Accident Notification......................................................................................................................... 14

Company Organization.......................................................................................................................... 14

Chief Pilot.......................................................................................................................................... 14

Pilot In Command.............................................................................................................................. 14

Appendix A............................................................................................................................................ 14

List of Approved Pilots....................................................................................................................... 14

List of Approved Aircraft.................................................................................................................... 15

Permission Acquisition Form (Sample)............................................................................................... 15

Revision Letter (Sample).................................................................................................................... 16

Appendix B............................................................................................................................................ 16

Certificate of Authorization ............................................................................................................... 16

Appendix C............................................................................................................................................ 16

Aircraft Manuals and Operational Guides.......................................................................................... 16

Exhibit 1: DJI Phantom 3 Professional............................................................................................. 16
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Exhibit 2: DJI Phantom 3 Professional User Manual........................................................................ 17

Exhibit 3: DJI Phantom 3 Professional Quick Start Guide ................................................................ 17

Exhibit 4: DJI Phantom 3 Professional Features.............................................................................. 17

Exhibit 5: DJI Phantom 3 Professional Specifications ...................................................................... 17

Exhibit 6: DJI Phantom 3 Professional Flight Controller System ...................................................... 17

Exhibit 7: DJI Phantom 3 Professional Smart Battery Manual ......................................................... 17

Exhibit 8: DJI Phantom 3 Professional Safety/Preflight Checklist and Guidelines Training ............... 17

Exhibit 9: DJI Inspire 1.................................................................................................................... 18

Exhibit 10: DJI Inspire 1 User Manual ............................................................................................. 18

Exhibit 11: DJI Inspire 1 Quick Start Guide...................................................................................... 18

Exhibit 12: DJI Inspire 1 Features.................................................................................................... 18

Exhibit 13: DJI Inspire 1 Specifications............................................................................................ 18

Exhibit 14: DJI Inspire 1 Flight Controller System............................................................................ 18

Exhibit 15: DJI Inspire 1 Smart Battery Manual............................................................................... 18

Exhibit 16: DJI Matrice 100............................................................................................................. 18

Exhibit 17: DJI Matrice 100 User Manual........................................................................................ 19

Exhibit 18: DJI Matrice 100 Features.............................................................................................. 19

Exhibit 19: DJI Matrice 100 Specifications ...................................................................................... 19

Exhibit 20: DJI Matrice 100 Smart Battery Manual.......................................................................... 19

Introduction

This Flight Operations Manual has been developed for use by On the Wave Productions and its founder, 

Harry Rabin, for the commercial use of small Unmanned Aerial Systems in the Closed-Set Filming 

Industry. Specifically, this Operations Manual has been created to be submitted along with On the 

Wave Productions’ Section 333 Exemption Petition in which the company seeks exemption from 14 

C.F.R. 91.119 (b) and (c) in order to provide commercial closed-set filming services in the United States 

of America. This Operations Manual will serve as a specific manual to be utilized by all personnel 

affiliated with an On the Wave Productions closed-set filming event. Furthermore, this manual will 

serve as a reference to both the Pilots In Command and Visual Observers highlighted within the Section 

333 Petition submitted by On the Wave Productions. All Pilots, Visual Observers, and other affiliated 

personnel performing an On the Wave Productions shoot utilizing a UAV will adhere to all FAA rules and 

regulations, conditions of the Exemption Petition, and operating guidelines as laid out in both this 

manual and the standard operating manual utilized by On the Wave Productions in their other 

commercial endeavors. 
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Purpose

The Purpose of this Operations Manual is to serve as a guide to all flight personnel operating Unmanned 

Aerial Systems for the purposes of closed-set filming at On the Wave Productions. Furthermore, this 

manual will serve as a guide in order to ensure the safety of all flight crew performing duties at On the 

Wave Productions as well as all participating parties who may be providing other services to the closedshoot. These other services may include acting roles, production roles, directing roles, sound roles, or 

the like. The safe integration of sUAS by On the Wave Productions is vital to successful, closed-shoots, 

and for this reason all participating subjects involved with a production that utilizes UAV Technologies 

will strictly follow the guidelines highlighted within this Motion Picture and Television Operations 

Manual. 

Organization Overview

Company Snapshot

On the Wave Productions is a film company that provides production and post services for the film 

industry in both the independent and feature film markets, for television and for government agencies 

including NSF, NOAA, and USGS. On the Wave Productions also produces its own films and TV shows 

mostly in the environmental/documentary based sectors. In addition, On the Wave Productions 

produces safety films for the oil industry and has worked with companies like Exxon and Mobile to 

produce training films for their employees.

Contact Information

On the Wave Productions

Harry Rabin

37 Humphrey Road

Santa Barbara, CA 93108

805-886-2204

onthewave@me.com

Designated Parties

As is highlighted within the Section 333 Exemption Petition accompanying this Motion Picture and 

Television Operations Manual, there are always at least two specific authorized personnel for each 

Unmanned Flight. These authorized personnel include the Pilot In Command and Visual Observer. 

Every unmanned operation at On the Wave Productions will utilize at least a two-person flight crew who 
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may or may not be assisted by further personnel during closed-set filming. In regards to the Pilot in 

Command, the initial PIC that will be designated by On the Wave Productions will be its founder, Harry 

Rabin, who has been piloting aircraft for over 30 years as a Private Pilot. His contact information can be 

found below;

On the Wave Productions

Harry Rabin

37 Humphrey Road

Santa Barbara, CA 93108

805-886-2204

onthewave@me.com

However, it should be noted that within the Petition for Exemption On the Wave Productions

ensures that all PIC’s, whether they are Mr. Rabin himself or a hired/contracted individual, 

satisfy the qualification, training, and operational guidelines as stated within the Conditions of 

the Exemption within the Exemption Petition. Thus, it is required for all PIC’s operating at On 

the Wave Productions to have satisfied the standards set by the company within their Petition. 

For this reason, if any person is tasked with operating a UAV at On the Wave Productions they 

should first refer to On the Wave Productions’ granted exemption paperwork to ensure that 

they satisfy these requirements;

1.) At least Recreational or Sport Certified Pilot

2.) Holder of a Valid U.S. Driver’s License

3.) Completed 25 hours of sUAS training

4.) Completed 10 hours of sUAS training on specific aircraft

Furthermore, in addition to the PICs, Visual Observers must also qualify for their positions as 

well. Thus, any On the Wave Productions personnel tasked with performing the duties of Visual 

Observer for a closed-set production must satisfy the qualification standards within the granted 

Petition for Exemption. These standards include adequate training and the holding of a valid 

U.S. Driver’s License. 

Participating Personnel

14 C.F.R. 91.119 (c) states; Except when necessary for takeoff or landing, no person may operate an 

aircraft closer than 500 feet to any person, vessel, vehicle, or structure. Within the Petition for 

Exemption On the Wave Productions requests exemption from this rule and cites other Closed-Set 

Filming operators who have been previously granted exemption, such as Skyworks Innovation, LLC 

(Exemption Number – 13779). For the same reasoning as is stated in the Skyworks decision, On the 

Wave Productions will allow persons, vehicles, and structures directly related to the film shoot to be 

nearer than 500 feet from the aircraft during the shoot so long as those people and controlling parties 

over property and structures grant permission to On the Wave Productions via a consent form. 

Specifically, On the Wave Productions will allow for participating personnel to be nearer than 500 feet 
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so long as an equivalent level of safety can be provided to these personnel based on the nature of the 

shoot, the environment of the shoot, and after an assessment of all the hazards associated with the 

flight and barriers protecting various participating parties in case of a crash. 

Area of Operations

On the Wave Productions will be operating sUAS for the purpose of commercial closed-set filming in 

operating areas outlined in the company’s Certificate of Authorization. Initially, On the Wave 

Productions will adhere to the blanket Certificate of Authorization granted to all Section 333 Petitioners 

who receive an Exemption Number. This current COA states that On the Wave Productions can operate 

their sUAS below 200 feet AGL (Above Ground Level), nationwide, so long as the operations take place 

within unaided visual line of sight and under the operating conditions stated within the Petition for 

Exemption and highlighted by the FAA. 

Plan of Activities

At least 3 days prior to any scheduled filming, On the Wave Productions will submit a written Plan of 

Activities to the local Flight Standards District Office having jurisdiction over the area that On the Wave 

Productions will be flying. Within this Plan of Activities, On the Wave Productions will provide the 

following mandated information;

1.) Date and Times for all flights,

2.) Name and Phone Number of the Operator of the sUAS Aerial Filming,

3.) Name and Phone Number of the person responsible for the on-scene operation of the sUAS,

4.) Make, Model, and Serial or N-Number of the sUAS to be used,

5.) Name and Certificate Number of sUAS PICs involved in the aerial filming,

6.) A statement that the operator has obtained permission from the property owners and/or local 

officials to conduct the aerial filming with the list of those who gave the permission available 

upon request to the inspector,

7.) Signature of the Exemption Holder or Representative, and;

8.) A description of the flight activity, including maps and diagrams of any area, city, town, county, 

and/or state over which filming will be conducted and the altitudes necessary to accomplish the 

operation.

Furthermore, the 3 day notification rule may be waived, however, On the Wave Productions will have to 

notify the Flight Standards District Office as soon as possible to request this waiver and be prepared to 

explain to the office why the 3 day notice is impractical. 

Permissions
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Prior to any flights above people, property, or structures it will be the duty of On the Wave Productions

to gain permission from these various parties and the controlling entities over property and structures. 

The permission to operate above these people and property may be gained in written or digital form, or, 

in some cases, verbal permission may be accepted. However, in most cases, On the Wave Productions

will gain permission via a digital form that is accepted by an individual or property owner on their Smart 

Phone or Tablet. This is similar to On the Wave Productions’ current practices when it comes to gaining 

consent from individuals who may be captured in one of their shoots. 

When On the Wave Productions collects these consent forms they will be housed on a server or saved 

on the Cloud until they are deleted. However, due to an abundance of caution, the Petitioner will save 

consent forms for at least 6 months and generally into the distant future due to the relatively small size 

of the files and large storage capacity online or on a hard-server. These files will be available at all times 

via the internet and will be available to the Inspector upon request. 

Cordon Procedure

As is stated within the Petition for Exemption, On the Wave Productions will always take precautions to 

close access to a filming area to non-participants. On the Wave Productions will accomplish this by 

meeting with Production Personnel prior to shoots and developing an action plan to cordon off areas 

necessary for filming operations. If the closed operating area is breached by a non-participant, the PIC 

will end the flight as is mandated within the Conditions of the Exemption within the Exemption Petition 

filed by On the Wave Productions.

Pre-Flight Meeting

Prior to any commercial UAV operation by On the Wave Productions for the purpose of closed-set 

filming, the flight crew and production staff will meet to go over all applicable rules, operating 

procedures and the like. This meeting will typically occur multiple days before the production but no 

less than one day before the production in an effort to give all participating personnel time to prepare 

for the flight. The Pilot In Command will take a leading role in these meetings and cover various topics 

relating to the flight, including;

1.) The COA provisions covering the flight.

a. Operating Area

b. Operating Altitude

2.) Any additional provisions mandated by the Flight Standards District Office with jurisdiction over 

the operating area.

3.) Operations Manual

a. Standard

b. Motion Picture and Television 

4.) Plan of Activities Information

5.) Aircraft Take-off and Landing Areas
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6.) Flight Crew Operating Area

7.) Emergency Situations

8.) Fail-Safe Discussion

9.) Concurrent Flight Operations by other aircraft during the time of operation

10.) Flight Hazards

11.) Risks to Participating Personnel (Collection Permission Forms)

12.) Cordon Procedures

FAA Sign-Off

The flights conducted by On the Wave Productions will adhere to all FAA rules and parameters not 

requested for exemption within the Petition for Exemption accompanying this Manual. Furthermore, all 

conditions within the finalized, granted Exemption will be strictly followed by On the Wave Productions. 

Through the granting of the Section 333 Exemption Petition and the release of an official exemption 

number, the FAA will allow for the commercial operations by On the Wave Productions for the purposes 

of closed-set filming so long as the operations follow all the rules and regulations of the FAA and the 

conditions stated within all On the Wave Productions’ Petitions, Manuals, and the like. 

Conditions to be Followed

1. Proposed operations using Small Unmanned Aircraft Systems in the United States under the 

granted form of this Petition for Exemption will be limited to the following aircraft, which all 

weigh less than 55 pounds including batteries and operational/technical payloads; DJI Phantom 

3 Professional, DJI Inspire 1, and DJI Matrice 100.

Furthermore, any aircraft outside of this comprehensive list for this Petition for Exemption will 

have to be added to an amended version of this petition or a new Petition for Exemption must 

be filed with the new flight platform(s).

2. The proposed use-cases/applications contained within this Petition for Exemption under Section 

333 are as follows; Cinematography, Closed-Set Filming, Environmental Protection, Fire, Law 

Enforcement, and Search and Rescue.

All of these flights will take place below 400 feet AGL nationwide unless otherwise advised in an 

ATO-issued Certificate of Waiver or Authorization. 

3. All flights conducted by On the Wave Productions will be below 400 feet AGL, operated within 

Visual Line of Sight, and have a live, GPS-based, read-out of altitude during the flight. 

Furthermore, each flight will begin with a “Zero Altitude” start point, thus creating an accurate 

AGL calculation. 
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4. All flights conducted by the Petitioner will be controlled by a trained flight crew consisting of a 

licensed (at minimum Recreational or Sport Pilot’s Certificate) PIC with a Medical Certificate or 

equivalent valid U.S.A. Driver’s license and a trained Visual Observer.

5. All flights conducted by the Petitioner will include aircraft that are flying below the 87 knot (100 

mph) airspeed maximum, highlighted by the FAA in their guidelines. 

6. All flights conducted by On the Wave Productions will be conducted within Visual Line of Sight, 

during daytime flying hours, and adhere to Visual Flight Rules under the Visual Meteorological 

Conditions associated with 400 foot AGL airspace. 

7. The Petitioner will not allow any PIC to operate a sUAS unless the PIC meets the qualification 

standards set by the Federal Aviation Administration (i.e. Minimum - Sport Pilot’s Certificate and 

Medical or U.S.A. Driver’s License) and by the safety guidelines and operational capabilities 

relating to safe sUAS operations, such as;

a. Evasive Maneuvers

b. Emergency Actions

c. Fail-Safe Knowledge

d. Flight Skills

i. Maintaining adequate distances from;

1. People

2. Property

3. Structures

4. Etc.

8. PIC qualification flight hours will be logged in a manner consistent with 14 C.F.R. 61.51(b). 

Additionally, a record of the PIC training will be documented and made available upon request 

by the Administrator. 

9. Training operations will only be conducted during dedicated training sessions. During training, 

all persons not essential for flight operations will be deemed nonparticipants, and thus, the PIC 

will operate the aircraft with appropriate distance from nonparticipants in accordance with 14 

C.F.R. 91.119. 

10. As highlighted by the FAA, the Visual Observer’s duty is to visually observe the relevant airspace 

for aircraft, hazards, obstacles, structures, or the like. For this reason, the VO will not be 

allowed to operate the camera or other instruments on the sUAS during flight operations. 

Instead, a third person will have to serve as a camera operator if the flight crew seeks a 

dedicated pilot and dedicated camera operator. 

11. The PIC, for the duration of an unmanned flight, will be named prior to the flight. Due to this, 

once the PIC is named and a flight is begun, the PIC will not be able to transfer his/her 

designation as the PIC through the duration of the flight. Furthermore, the PIC is the Captain of 

the flight crew and will ensure that the Visual Observer is qualified to hold the VO position for 

the duration of the flight. 
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12. Each commercial sUAS flight performed by On the Wave Productions will be planned for ahead 

of the flight date. This will be to ensure adequate time for all participants to prepare and to 

obtain all the necessary permissions (landowners, homeowners, property owners, etc.) if any 

are needed. All flights will be preceded by a meeting at least one day before the flight at which 

all participants of the flight will be present. This is to ensure adequate knowledge and 

preparedness prior to the sUAS flight. 

13. Aircraft maintenance is obviously vital for any commercial sUAS operation. It ensures safety and 

is necessary prior to each flight to maintain safe, efficient, and effective flight operations. Once 

again, the PIC, as the captain of the flight crew, will take a leading role in inspecting the aircraft 

prior to flight. The PIC will likely have the most experience of anyone on the flight crew and will 

be in tune with the specific maintenance needs of each specific flight craft. If the PIC were to 

find an error in the flight craft or any of the associated systems, including the Ground Control 

System for example, he/she would ground the flight until adequate maintenance is completed 

and the aircraft is once again safe to fly. All maintenance on flight crafts utilized by the 

Petitioner will be noted and logged to ensure the safety of all aircraft and the people operating 

them. 

14. Relating to the above Condition, anytime a flight-critical component is replaced or anytime 

there is mission-critical maintenance on the craft, the PIC will conduct a flight test of the system 

before completing the intended, commercial mission. Once again this flight test will be logged 

by the PIC. 

15. Routine maintenance and inspections of the sUAS will be logged by the PIC in accordance with 

the requirements and suggestions laid out by the aircraft manufacturer in terms of aircraft 

component maintenance, overhaul, replacement, inspection, and life limits, which are part of 

the supporting documents for each aircraft below in the aircraft-specific exhibits. The logging of 

these maintenance/inspection checks will be included in the aircraft records and include the 

total time of service and description of work. 

16. All sUAS flights will be conducted within Visual Line of Sight (“VLOS”) of both the PIC and VO at 

all times. Furthermore, VLOS means visual observance unaided by any device other than 

corrective lenses such as eye glasses or contacts. The use of telescopes, FPV systems (for 

purposes of VLOS flights), binoculars, and the like will not be permitted. Also, both the PIC and 

VO should be in constant, verbal communication range. The use of other devices to 

communicate out of verbal range are not permitted. These devices would include, cell phones, 

text messaging, walky-talkies, and the like. 

17. No commercial flight missions will be executed unless it can be determined that the flight crew 

can complete their mission from take-off through landing, with a reserve of 25% battery life. 

The Petitioner’s newest flight crafts have adaptive battery monitors and, for this reason, this 

condition will be an automated process as the Petitioner can set the default Advisory and 

Critical Battery warnings to 35% and 30% respectively, which will warn the PIC of the depleted 

battery and engage him/her to fly home and land with 25% remaining power. For all On the 

Wave Productions systems without this automated feature, a watch will be used to monitor 

flight times to ensure a safe return home with adequate battery power. However, due to the 
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revolving adoption of the newest flight platforms and the current stock of new generation flight 

crafts, the overwhelming majority of sUAS flights after the granting of this exemption will utilize 

a Smart Battery System. 

18. In the case of an unexpected obstacle or in-flight issue, each sUAS the Petitioner operates will 

have the ability to abort a mission and take corrective actions. 

19. The sUAS utilized by On the Wave Productions will be programmed so that if the sUAS loses 

signal with the PIC or Ground Control Station during flight, the system will return to a 

preprogrammed GPS location located within the operating area containing the flight crew. 

Furthermore, this failsafe can also be used in controlled situations, meaning the failsafe will be 

able to be engaged should something happen on the ground that disallows the PIC from bringing 

the sUAS back in a normal fashion. Additionally, in both situations described above, where the 

failsafe is either a controlled action from the pilot or an uncontrolled situation, like radio-link 

signal loss, the unit will not only fly back to its preprogrammed home point, it also has the ability 

to land itself. This allows safe operations of the aircraft even in troublesome situations, such as 

signal loss, and prevents the unit from flying off uncontrollably or landing in an unknown 

location. 

20. The operating documents required under 14 C.F.R. 91.9 and 91.203 will be maintained and 

available to the PIC at the Ground Control Station of the aircraft anytime the sUAS is operating. 

Furthermore, these documents will be available for review by the Administrator or other law 

enforcement officials upon request and are additionally contained in Exhibit 1, with appropriate 

links to the specific flight manuals of each flight craft requested in this Petition for Exemption. 

21. It is always important to specify precedent when determining operating practices. For this 

reason, if a discrepancy exists between the conditions laid out in this Petition for Exemption and 

the actual Granted Exemption, the conditions laid out in the finalized Granted Exemption will 

take precedent over the conditions laid out in this Petition. Furthermore, if there are no 

discrepancies between the Petition and Grant of Exemption, the Petitioner will follow the 

procedures outlined in the Operating Documentation below. Additionally, if any changes are 

made to the Operating Procedures and Documentation contained in this Petition for Exemption, 

the Petitioner will present the updated documents upon request to the Administrator. Also, 

should the Petitioner determine that an update or change to the procedures or documentation 

would affect the basis of the approved version of this Petition for Exemption, the Petitioner will 

either file for an amendment to the existing Exemption or create a new Petition with the 

revisions. 

22. As has been noted, the Petitioner will obtain written, digital, and/or oral permission from the 

landowners, farmers, property owners, or otherwise authorized agents for flights above their 

property. 

23. The Petitioner will also obtain all required permissions and permits from territorial, state, 

county or city jurisdictions, including;

a. Law Enforcement
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b. Fire Departments

c. Municipal Agencies, or;

d. Other Appropriate Governmental Bodies 

24. The Petitioner will not conduct operations at night. Furthermore, all operations will be 

conducted under Visual Meteorological Conditions (“VMC”).

25. The Petitioner is aware of the need to obtain an Air Traffic Organization (“ATO”) issued 

Certificate of Waiver or Authorization (“COA”) prior to conducting operations under the grant of 

exemption. The Petitioner intends to fly under the Blanket COA provided by the FAA in March 

of 2015 for flights below 200 feet to all Section 333 Exemption holders or under a future ATOissued COA that will be applied for by the Petitioner after receiving their Section 333 Exemption 

Number. 

26. All sUAS flights conducted by the Petitioner will be done so in accordance with airspace 

requirements established by the FAA and/or an ATO-issued COA, including;

a. Class of Airspace

b. Altitude Level, and potential;

c. Transponder Requirements

27. As has been stated, the sUAS will not be operated within 5 nautical miles of an airport reference 

point as noted on a current FAA-published aeronautical chart unless a letter of agreement with 

that airport’s Air Traffic Control is obtained, and the operation is conducted in accordance with 

a NOTAM as required by the Operator’s COA. 

28. As stated previously, the Petitioner will follow VMC guidelines for VFR flights and as such, will fly 

only when there is visibility equal to, or in excess of, 3 statute miles from the PIC, while 

maintaining an adequate distance of no less than 500 feet below, or less than 2,000 feet 

horizontally from a cloud.

29. All operations by the Petitioner will be conducted below 400 feet AGL, nationwide, or as 

otherwise advised in an ATO-issued COA. 

30. All sUAS craft flown by the Petitioner will be marked and identifiable by a serial number which 

will be as large as practicable given the relatively small size of the aircraft. The FAA has 

previously stated that so long as the markings are as large as practicable given the size of a 

sUAS, an equivalent level of safety can be achieved. 

31. All aircraft utilized by the Petitioner operate via radio frequency, which is governed by the 

Federal Communications Commission (“FCC”). For this reason, prior to commercial operations 

under a granted Section 333 Exemption, the Petitioner will ensure the radio frequency spectrum 

used to operate and control its sUAS complies with FCC or other appropriate government 

oversight agency rules and regulations. 

32. As is stated in the FAA guidelines, a sUAS is required to yield the right of way to all manned 

aircraft and aviation operations at all times. This rule will be strictly followed by the Petitioner. 
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33. The concentration of a PIC is necessary for safe operations. It is for this reason that the 

Petitioner will not allow any sUAS operations while a PIC is in a moving device or vehicle. These 

vehicles would include things like;

a. Cars/Trucks/SUVs

b. Boats

c. Tractors

d. ATVs

34. All sUAS operations by the Petitioner will be conducted at least 500 feet from all 

nonparticipating people, vessels, vehicles, and structures, unless the following conditions apply;

a. Protective barriers are present that adequately protect nonparticipants from flying 

shrapnel or debris should there be an accident. Furthermore, should a nonparticipant 

leave this safe-zone, the PIC will end the flight. 

b. The Petitioner has been granted permission to operate near a vessel, vehicle, or 

structure by the owner/controller of these properties. In addition to permission, the PIC 

will also have to perform a risk assessment of the situation and potential obstacles/flight 

hazards and determine the safety of the flight. If it is determined that the hazards 

present no risk, the PIC can start the mission. 

c. Non-participants become official participants by consenting to be involved in the film or 

television production and they adhere to all the guidelines stated within the Petitioner’s 

Motion Picture and Television Operating Manual (“MPTOM”).

35. The Petitioner will log and report to the UAS Integration Office within 24 hours of any incident, 

accident, or flight operation that occurred outside the horizontal and vertical boundaries of the 

operational area as defined by the COA under which the flight was operating. Furthermore, the 

Petitioner will report accidents to the National Transportation Safety Board (NTSB).

36. The Petitioner will provide additional flight training to PICs that may be towing objects in the 

event of an exemption from 14 C.F.R. 61.315 (c) (18). In the event that the Petitioner is exempt, 

each PIC that is designated as being a potential candidate for flying a sUAS while towing an 

object will be required to undergo additional training, on top of their required training and 

certifications, that will consist of 10 hours of training flights while towing objects. These objects 

will be dummy banners that weigh no more than the max weight allowable to satisfy the max 

takeoff weight specifications as highlighted by the manufacturer for each flight craft. 

Furthermore, the 10 hours of training will be required for each aircraft type, thus giving the PIC 

adequate training time and experience while towing objects with specific flight crafts. This will 

be necessary to familiarize each PIC with each specific flight craft in order to learn how specific 

flight craft respond to towing objects, particularly with regard to downwash and wind. 

Additionally, of the 10 total flight hours required for training on towing objects, 5 of these hours 

must be in the max wind tolerances as specified by the manufacturer for each flight craft. 

Training in these conditions will hone the skills of each PIC and allow them to operate in the 
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worst case scenario for towing objects, which is high wind. When conducting actual commercial 

flights while towing objects, the Petitioner will not conduct flights in conditions where sustained 

winds are more than 75% of the maximum wind tolerance of the aircraft or when there are wind 

gusts in excess of 75% of the maximum wind tolerance as specified by the manufacturer for 

each aircraft. 

37. The Petitioner for this Exemption is requesting permission to operate sUAS for the purposes of 

commercial, closed-set filming. Due to this the Petitioner will submit a Motion Picture and 

Television Operations Manual (“MPTOM”) along with this Petition. 

38. Relating to the MPTOM, the Petitioner will submit a written Plan of Activities to the local Flight 

Standards District Office (“FSDO”) with jurisdiction over the area of proposed filming, at least 

three days prior to conducting commercial flights. As referenced in previous grants for 

exemptions of Closed-Set Filming, the three day notification period may be waived with 

concurrence of the FSDO. Furthermore, the Plan of Activities paperwork submitted to the FSDO 

will include at least the following;

a. Date and Times for all flights,

b. Name and Phone Number of the Operator of the sUAS Aerial Filming,

c. Name and Phone Number of the person responsible for the on-scene operation of the 

sUAS,

d. Make, Model, and Serial or N-Number of the sUAS to be used,

e. Name and Certificate Number of sUAS PICs involved in the aerial filming,

f. A statement that the operator has obtained permission from the property owners 

and/or local officials to conduct the aerial filming with the list of those who gave the 

permission available upon request to the inspector,

g. Signature of the Exemption Holder or Representative, and;

h. A description of the flight activity, including maps and diagrams of any area, city, town, 

county, and/or state over which filming will be conducted and the altitudes necessary to 

accomplish the operation.

39. Flight operations may be conducted closer than 500 feet from participating persons consenting 

to be involved and necessary for the filming production, as specified in the Exemption Holder’s 

MPTOM. 

Communications

Prior to each commercial flight performed by On the Wave Productions the Pilot In Command will 

develop a plan to ensure adequate communications with all participants in the sUAS flight. These 

communications may be visual, verbal, or via radio communication. However, as is stated in the 

conditions above, the actual flight crew must stay within verbal communication range, meaning the Pilot 

In Command and Visual Observer can communicate verbally without radio assistance. Other 

participants may be out of this range as they are not critical to the actual flying of the aircraft. 

Nonetheless, if possible, On the Wave Productions will always attempt to keep all participants within 

verbal communication range.
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Accident Notification

As is stated in the Conditions above, On the Wave Productions will notify the National Transportation 

Safety Board in the event of any accidents utilizing sUAS aircraft. 

Company Organization

Chief Pilot

The Chief Pilot at On the Wave Productions will be Mr. Harry Rabin. As the Chief Pilot he will be the lead 

for all UAV operations and as such, will have several specific duties beyond his regular duties as simply a 

Pilot In Command. These duties include;

1.) Ensuring the qualifications of each Pilot In Command employed by On the Wave Productions

2.) Acting as the contact for all FAA discussions on behalf of On the Wave Productions

3.) Ensuring all pilots are well versed on the company aircraft

4.) Ensuring all pilots have a copy of both the Standard and Motion Picture and Television 

Operations Manuals

5.) Oversee any changes to the Operations Manual and ensuring that these changes are 

disseminated to all the pilots and other participating personnel 

Pilot In Command

The Pilot In Command of sUAS at On the Wave Productions will be responsible for the safe and effective 

utilization of the aircraft during commercial flights. The duties of the Pilot In Command can be found 

above in the Conditions to be Followed Section. In short, the Pilot In Command is the captain of the 

flight crew and is responsible for safe and legal operations. This means ensuring all aircraft are suitable 

for flight, all personnel are qualified for their positions and located in the right areas, all cordon 

procedures have been executed, all flight maneuvers are within appropriate airspace as specified by the 

COA, and the like. 

Appendix A

List of Approved Pilots

Revisions may be made to this section as more Pilots In Command are added, however, initially, the 

main Pilot In Command at On the Wave Productions will be;
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Harry Rabin

Class: Private Pilot

Pilot Certificate Number: 3684221

37 Humphrey Road

Santa Barbara, CA 93108

805-886-2204

onthewave@me.com

List of Approved Aircraft

Proposed operations using Small Unmanned Aircraft Systems will be limited to the following aircraft, 

which all weigh less than 55 pounds including batteries and operational/technical payloads; 

1.) DJI Phantom 3 Professional

2.) DJI Inspire 1

3.) DJI Matrice 100

Permission Acquisition Form (Sample)

The following is a sample form that will be filled out by participating personnel granting On the Wave 

Productions permission to operate their sUAS at below 500 feet above the participants, their property, 

etc.

By signing this form I agree to grant permission to On the Wave Productions, its pilots, and other 

operating personnel, for the purposes of filming above me, my property, or in some operating area in 

which I am present, below 500 feet, for the purpose of closed-set filming. 

NAME:_____________________________________________________________________

TITLE:_____________________________________________________________________

BASIS OF AUTHORITY TO GRANT PERMISSION:___________________________________

LOCATION:_________________________________________________________________

DATE OF OPERATION:________________________________________________________
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SIGNATURE:_______________________________________________________________

DATE:____________________________________________________________________

On the Wave Productions Representative Receiving Permission:____________________

Revision Letter (Sample)

Revision# Section Page# Action Remarks Initial

_____________________________________________________________________________________

_____________________________________________________________________________________

_____________________________________________________________________________________

_____________________________________________________________________________________

_____________________________________________________________________________________

_____________________________________________________________________________________

_____________________________________________________________________________________

_____________________________________________________________________________________

_____________________________________________________________________________________

Appendix B

Certificate of Authorization

On the Wave Productions will initially be operating under the Blanket 200 Foot COA granted to all 

Section 333 Petitioners granted an Exemption Number. Once this Petition is approved, the COA file will 

be linked here.

Appendix C

Aircraft Manuals and Operational Guides

Exhibit 1: DJI Phantom 3 Professional

http://www.dji.com/product/phantom-3
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Exhibit 2: DJI Phantom 3 Professional User Manual

http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.2_en.pdf

Exhibit 3: DJI Phantom 3 Professional Quick Start Guide

http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_Quick_Start_Guide_en.pdf

Exhibit 4: DJI Phantom 3 Professional Features

http://www.dji.com/product/phantom-3/feature

Exhibit 5: DJI Phantom 3 Professional Specifications

http://www.dji.com/product/phantom-3/spec

Exhibit 6: DJI Phantom 3 Professional Flight Controller System

http://www.dji.com/product/phantom-3/flight-system

Exhibit 7: DJI Phantom 3 Professional Smart Battery Manual

http://download.djiinnovations.com/downloads/phantom_3/en/Intelligent_Flight_Battery_Safety_Guidelines_en.pdf

Exhibit 8: DJI Phantom 3 Professional Safety/Preflight Checklist and Guidelines Training

http://download.dji-innovations.com/downloads/phantom_3/en/Safety_Guidelines_Disclaimer_en.pdf
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Exhibit 9: DJI Inspire 1 

http://www.dji.com/product/inspire-1

Exhibit 10: DJI Inspire 1 User Manual

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf

Exhibit 11: DJI Inspire 1 Quick Start Guide

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_Quick_Start_Guide_en.pdf

Exhibit 12: DJI Inspire 1 Features

http://www.dji.com/product/inspire-1/feature

Exhibit 13: DJI Inspire 1 Specifications

http://www.dji.com/product/inspire-1/spec

Exhibit 14: DJI Inspire 1 Flight Controller System

http://www.dji.com/product/inspire-1/flight-control

Exhibit 15: DJI Inspire 1 Smart Battery Manual

http://download.djiinnovations.com/downloads/inspire_1/en/Intelligent_Flight_Battery_Safety_Guidelines_en.pdf

Exhibit 16: DJI Matrice 100 

http://dev.dji.com/en/products/flying-platforms/matrice-100
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Exhibit 17: DJI Matrice 100 User Manual

http://download.dji-innovations.com/downloads/dev/Matrice/en/M100_User_Manual_v1.0_en.pdf

Exhibit 18: DJI Matrice 100 Features

http://dev.dji.com/en/products/flying-platforms/matrice-100/features

Exhibit 19: DJI Matrice 100 Specifications

http://dev.dji.com/en/products/flying-platforms/matrice-100/specs

Exhibit 20: DJI Matrice 100 Smart Battery Manual

http://download.djiinnovations.com/downloads/dev/Matrice/en/Intelligent_Flight_Battery_Safety_Guidelines_en.pdf